NAB: 1,978 Stations Lose Coverage With FCC Repack Software

WASHINGTON—The areal reach of most TV stations in the United States will be
diminished in the post-incentive auction repack by the government’s current
technology. That’s the conclusion of the National Association of Broadcasters,
which ran its own comparative analysis on TVStudy,
the software created by the Federal Communications Commission for the repack.

“The issue is… not an abstract legal or technical question, but one that has real-world consequences,” the NAB said in
comments filed with the FCC this week. “Changes in coverage area and population
served produced by the use of TVStudy
will impose substantial burdens both on broadcast licensees that participate in
the auction, and those that are subject to channel changes through the commission’s subsequent repacking
process.”

TVStudy is based on OET-69, the FCC’s
predictive methodology for TV signal reach and interference. TVStudy uses updated data compared to
OET-69 as it was when Congress passed the Spectrum Act in February of 2012. The
NAB says Congress intended the repack to be done with the version of OET-69
established at the time of the law’s passage.

However, the NAB says that even plugging in OET-69 parameters into TVStudy leaves 88 percent of U.S. full-power
and Class A TV stations—1,978 out of 2,232—with less coverage. Of
those, 84 percent or 1,668 would lose between one-half and five percent of
their coverage area, while 8 percent or 151 would lose more than 5 percent.

NAB’s analysis also indicated that 45 percent or 1,009 of the TV stations in
the sample would lose viewers using TVStudy
with OET-69 values plugged in. Of those, 45 percent or 448 stations would lose
between 0.5 and five percent of their audience. About 11 percent, or 110
stations, would love more than 5 percent.

In a side-by-side comparison, using the same data in TVStudy and the February 2012 version of OET-69, TVStudy knocked down the coverage area
for more than half of the sample. Since the commission has not identified the
parameters and switch settings it will use for the spectrum auction, the NAB
set theoretical ones. E.g., population data, beam-tilt, grid size, terrain
profile resolution and so forth—more than 100 in all.

In the side-by-side comparison, 249 stations lost more than 5 percent of their
coverage area with TVStudy versus
OET-69.

“Certain results are particularly
egregious,” the NAB filing said. “For example, full-power station WKPC-TV in
Louisville, Ky., is calculated to cover 15,207 square kilometers using the
current OET-69 methodology, but only 12,984 square kilometers—a 13.8 percent
loss of area—using the TVStudy software.”

More than half of stations also lost eyeballs, with 116 losing more than 5
percent of their audience. WLTV-TV in Allentown, Pa., for example, lost around
10 percent of its audience—471,332 of its 4,838,490 viewers. WFXQ-DC in
Springfield, Mass., lost 16.6 percent. KKFX-CA in San Luis Obispo, Calif., lost
48 percent.

The NAB’s filing suggested a legal strategy should the commission pass
an incentive auction order adopting the software as it is.

“If the commission adopts TVStudy as it currently stands, and in
express contravention of unambiguous Congressional intent, the commission will
be acting in a manner that is arbitrary, capricious and contrary to law,” the
filing said.

March 21, 2013, “NAB
Says OET-69 Changes ‘Unlawful’ and ‘Flawed’”
Proposed changes in how a TV station’s reach is calculated are “fundamentally
flawed in their execution” if not entirely “unlawful,” the NAB said today in a
filing with the FCC.

August 20, 2013, “TVStudy Update No. 3 Does Cross-Border Analysis”TVStudy Vers. 1.2.7 is said to be
able to perform cross-border channel analysis of TV signal interference between
stations in the United States and those in Canada and Mexico “on proxy
channels.”

September 9, 2012, “FCC
TVStudy Update No. 4 Tweaks Beam-Tilt”
The update includes new source code and executable files for both the Mac and
Linux platforms, an updated instruction manual, change log, and upgrade
guide.